Summary:
The topic of quarantine in relation to Yellowstone buffalo has
received significant attention in recent years, particularly
in the past few months. USDA’s Animal and Plant Health
Inspection Service (APHIS), with assistance from the MT Department
of Fish, Wildlife and Parks (FWP), has recently approved the
first phase of a quarantine feasibility study. The study involves
taking 100 buffalo calves captured under the Interagency Bison
Management Plan when the population of the Yellowstone herd
numbers more than 3000. At least half the buffalo will be slaughtered
and culture tested for brucellosis. The remaining buffalo will
be held over for phase two, which is expected to be similar
in nature. If any buffalo remain after phase two, they will
enter phase three, the calving phase. More buffalo will be slaughtered
and tested. If any buffalo remain, they may be placed at their
final release site to be held behind a fence for one more year
and then finally released as “wild” buffalo. The
buffalo will be held in a 400-acre facility for phase one. They
will be periodically tested for brucellosis and artificially
fed as necessary. Future phases of the study will occur at similar
sites. While this is not the only possible scenario for quarantining
Yellowstone buffalo, it is the only one currently under consideration
by APHIS. APHIS has not prioritized the development of alternative
diagnosis tools for brucellosis or potential novel treatments
for the disease. Further, AHPIS has adamantly objected to tribal
involvement in the quarantine process.

Problems with quarantine of Yellowstone Buffalo: 1. Genetics: The Yellowstone buffalo herd is
unique. Yellowstone buffalo are the only buffalo with a continuous
history of being wild and unfenced. They are genetically unique,
exhibiting the highest level of genetic diversity of all buffalo
in the world. Actions which remove a very specific segment of
the Yellowstone herd will have drastic impacts on the genetic
diversity of targeted subpopulations. Specifically, the APHIS
plan calls for removing 80 female buffalo calves and 20 male
calves on an annual basis. While no analysis has been conducted
on the impacts to this specific population, it is likely that
such a removal will constitute a 50% reduction in female calves
that have survived their first winter. Because selection will
also include the slaughter of sero-positive calves and only
involve those that migrate out of Yellowstone, the specific
impact on the subpopulation from which the test subject calves
derive will be devastating to the future of that subpopulation.

2. Domestication: Quarantine of the extent
proposed by APHIS for Yellowstone buffalo is not consistent
with standard wildlife management practices. Quarantine periods
of short duration have been used with other species with some
success and with significant impacts to the quarantined animals
once released. The type of quarantine proposed is specifically
a technique for domestic livestock. The quarantined buffalo
will be subjected to human handling throughout the process and
will receive supplemental feed. They will be isolated from other
members of the herd from which they learn the techniques necessary
for survival in the wild. They will be exposed only to other
buffalo in their age class and will lose the family structure
characteristic of wild animals. Breeding will occur in captivity
with male buffalo that will not compete for breeding rights,
thus disturbing the natural selectivity and behavior that would
be exercised in the wild. Quarantine, captive breeding, and
artificial feeding will cause a breakdown of family structure,
unnatural breeding patterns, and a general loss of skills learned
from natural settings and seasonal migration. In short, the
buffalo that survive quarantine will be much like domestic buffalo
and therefore will not benefit species conservation. They will
be like other captive herds, which would make a more suitable
population for such programs.

3. Purpose and Need: Quarantine has been proposed
for Yellowstone buffalo in the context of a need to control
population growth and to promote restoration of buffalo to other
areas. However, population pressures are due to artificial constructs.
The target population of 3000 buffalo for Yellowstone National
Park is not based on the ecological carrying capacity of the
park. Further, if winter range habitat is extended for the buffalo,
the potential for greater populations of buffalo will be greatly
expanded. If those extensions of habitat are consistent with
migratory patterns, it is possible for buffalo to naturally
move to areas currently considered for the placement of quarantined
buffalo. Management plans to address the risk of brucellosis
transmission could be developed for the new areas to insure
the retention of Montana’s brucellosis class free status.

4. Native American Tribes: Native American
tribes, who have a vested interest in the restoration of buffalo
to tribal lands, have not been included in the planning and
development of buffalo relocation proposals. Tribal reservation
lands present the best possible scenario for buffalo relocation
programs because as sovereign nations, the tribes have a greater
ability to manage land use to be consistent with the principles
of quarantine without the need for the domesticating influence
of small heavily regulated pastures and artificial feed.
Conclusion: Quarantine is an inappropriate tool for Yellowstone
buffalo. The genetic uniqueness and historical significance
of Yellowstone buffalo requires that management decisions be
carefully considered and thoroughly evaluated. Quarantine of
the nature proposed is exclusively suited for domestic animals
and is not consistent with accepted wildlife conservation practices.
Quarantine that focuses on specific population segments, age,
and sex classes will have a drastic effect on the genetic diversity
of the buffalo. Such selection will compromise the future of
the buffalo that remain in Yellowstone and will not succeed
in creating other herds with the cherished characteristics of
the Yellowstone buffalo. The need for invasive population management
and relocation of buffalo should be discussed in the context
of expanded habitat options in the Greater Yellowstone Area.
Native American tribes must be involved in the development and
implementation of buffalo restoration projects. Respect for
the sacred nature of Yellowstone buffalo must be at the forefront
of decisions determining their future.

Talking
Points for Quarantine EA Phases II and III
The Final Environmental Impact Statement (FEIS) for the Interagency
Bison Management Plan (IBMP), to which the agencies have tiered
the quarantine EA is inadequate in its discussion of the long-term
impacts of a large scale quarantine program on the remaining
population of bison in and around Yellowstone National Park.
Additionally, circumstances surrounding bison management have
changed dramatically from the expectations of the IBMP after
five years of implementation. Most importantly, habitat that
is supposed to be currently available for bison is still denied
and bison are currently being captured and will be slaughtered
because of this failure. Quarantine, according to the FEIS is
supposed to be a tool for use when socially acceptable conditions
have been met. The current structure of bison management is
woefully inadequate to provide for the long-term future of free-roaming
wild bison within and surrounding Yellowstone National Park.
In other words, the preliminary conditions for pursuing a plan
to quarantine bison have not been met. The agencies must focus
attention on reorganizing the IBMP to reflect the current situation.
Rather, with this plan, the agencies are moving full steam ahead
with some aspects of the Plan while ignoring the most important
issues for the future of wild free-roaming bison in the Greater
Yellowstone Area. As much as 5 million dollars will be spent
on this quarantine experiment over the next 6 years. This money
and associated resources could be better spent resolving land
use conflicts to gain sufficient habitat for the current population
of bison making one of the supposed needs for quarantine obsolete.

The desire to pursue this quarantine experiment will influence
the agencies decisions as to capturing bison, particularly on
the western boundary where the agencies have primarily used
hazing over the past three years instead of the massive capture
operations that will be required to fill the quarantine facility.
The process began last spring as the Montana Dept. of Livestock
(MDOL) captured nearly 200 wild buffalo, sending 96 to slaughter,
in order to attain 17 brucellosis test negative calves for quarantine.
This number was later reduced to 14 because three of the bison
later tested positive for the bacteria. Therefore, to achieve
the desired 100 calves in each of two years of the experiment,
the agencies will capture thousands of wild buffalo, sending
at least half to slaughter. Once captured, the agencies could
choose to send all bison except those quarantined to slaughter
as is currently the case with operations at the north boundary.
While the agencies claim that the quarantined bison would otherwise
be slaughtered, the truth is that the there is room for flexibility
in the IBMP as evidenced by the operations in the western boundary
area in 2003 and 2004 when relatively few bison were captured
and slaughtered even though the herd exceeded the target population
of 3,000.

The justification for implementing the quarantine experiment
is that the population currently exceeds 3,000, the IBMP target.
However, this number is entirely arbitrary and is supposed to
be subject to the adaptive management process. 3,000 is supposedly
the number of bison that the agencies can manage effectively
for spatial and temporal separation between wild bison and domestic
cattle that may graze in the area. However, since implementation
of the IBMP in 2001, the population has remained consistently
over 3,000 and there has been no concern expressed by the agencies
about managing for temporal and spatial separation. Additionally,
the definition of temporal separation is subject to the adaptive
management process, yet modifications based on the latest science
have still not been considered. Montana still retains its brucellosis
free status and there is no current threat to that classification
based on the population of bison in and around Yellowstone National
Park. In other words, the supposed need for quarantine is unjustified
based on a review of the current situation.

The Phase II facility description in the preferred alternative
specifies a total pasture area of 60 acres for 50 captive two-year
old bison. According to the description, the acreage will be
divided with 25 bison housed in a 30-acre pen for at least one
full year. This constitutes cruel and inhumane treatment on
its face and is a far cry from the 400-600 acres originally
described in the scoping process for bison quarantine that began
in 2003. The agencies claim that this site is most appropriate
precisely because of its small scale. The originally planned
Phase II site at Daily Lake is much larger but garnered criticism
from elk hunters because the land was originally purchased as
elk winter range and may interfere with elk migrations. The
agencies have entirely sacrificed the minimal well being of
the quarantined bison by choosing this miniscule site.

Analysis in the FEIS for the IBMP of bison quarantine does not
discuss impacts significant to the human environment beyond
a cursory discussion of the economic impact on Native American
tribes of receiving live bison. Even this discussion is not
relevant to the current proposal because of the restriction
on using quarantined bison for commercial uses outlined throughout
the environmental review process. Neither does the purpose and
need section adequately analyze bison quarantine. The requirement
established in the FEIS to “initiate separate NEPA analysis
to determine the location, design, and operation of such a facility”
(p194) does not satisfy the intention of NEPA to fully analyze
significant impacts to the human environment. Therefore, the
required level of analysis is a complete Environmental Impact
Statement of the entire bison quarantine protocol. Additionally,
while certain components of this project are considered experimental
and may not have long-term impacts, the fact remains that bison
that finish the experimental protocol will be relocated outside
the GYA and will be used to found additional bison herds. There
are significant long-term impacts both on the bison currently
residing in the GYA and to the overall conservation effort for
bison in North America.

The agencies should conduct a full Environmental Impact Statement
for the full scope of bison quarantine. According to 40 CFR
1508.25, the scope of the analysis should include all phases
of bison quarantine from the assembling of bison calves in phase
1 to the placement of certified brucellosis negative bison outside
the GYA, including the implications of a successful quarantine
protocol on the remainder of the bison population within the
GYA. Segmentation of the analysis of this program masks the
significant impacts on the human environment and ignores the
cumulative impacts of this undertaking.

4/14/05
Dear Reviewer:
Please accept the following comments on the proposal to develop
phases 2 and 3 of a bison quarantine feasibility study on behalf
of the Buffalo Field Campaign and myself.

The primary issues that are of concern with the continuation
of a quarantine feasibility study involve:
1. The humane treatment of bison throughout the process of capture,
handling, and transport of bison from YNP and the facility design
and handling procedures in the various facilities.
2. The domestication of bison that “graduate” from
the study for release.
3. The impacts of removing seronegative bison calves that might
otherwise be released on the dynamics of bison herds within
the Park and in surrounding areas.
4. The potential for quarantine to be used as an excuse to continue
with the intensive management actions of the IBMP rather than
employ the adaptive mechanisms of the Plan that might allow
for greater tolerance of untested bison in an expanded range.
5. The lack of a corresponding process of NEPA compliance from
APHIS.
6. The overall cost of the project and the lack of a cost/benefit
analysis of alternative means to expand the range of YNP bison.

HUMANE TREATMENT
The current methods employed by the Montana Deptartment of Livestock
and cooperating agencies for capturing, testing and transporting
bison lack a concern for the well being of bison in general
and demonstrate the need for a specific protocol for the humane
treatment of bison as wildlife. Current practices cause significant
and unnecessary stress on captured animals. Operations typically
involve running bison at an aggressive pace for more than ten
miles to the Duck Creek trap using snowmobiles, horses, ATV’s,
helicopters and cracker rounds. The bison enter the facility
in fear and are then subjected to intensive handling by livestock
agents who appear to demonstrate a particular zeal in using
aggressive livestock techniques including excessive use of “hot
shot” cattle prods and overhead activity. The FEIS for
the IBMP discusses humane treatment techniques that would minimize
stress and injury to bison in capture facilities. Montana Livestock
agents at the Duck Creek facility and NPS agents at Stephen’s
Creek have blatantly disregarded these recommendations and continue
to treat captured bison inhumanely in the facilities. While
there are currently no laws to protect wild bison from inhumane
treatment, there is a legal basis for humane treatment of bison
in research and quarantine facilities. If bison captured at
Duck Creek and Stephen’s Creek are bound for quarantine,
then the Animal Welfare Act should apply from the initial handling
of the bison and throughout the process of quarantine. The current
facilities at Duck Creek and Stephen’s Creek are not sufficient
to guarantee the well being of bison. Many bison are injured
in the facilities, (one bison died awaiting transport at the
Stephen’s Creek facility due to injuries sustained in
captivity) the design of both facilities contributes to both
stress and injury, agents are not trained or certified to handle
wild bison in the facilities according to a protocol for humane
treatment standards, no independent review of the Duck Creek
facility has been allowed by the agencies while bison are captive,
and a comprehensive and enforceable standard for humane treatment
of bison in handling facilities has not been established or
implemented.

Details of quarantine facility design at Brogans and Dome Mountain
should be made available to the public. An independent review
of the facilities should be conducted and recommendations implemented
before any bison are placed in facilities. Both facilities should
be openly accessible to the media and independent observers
to ensure humane treatment of bison. The facilities and protocol
for transport and handling of bison should be in compliance
with the Animal Welfare Act and should be made available to
the public for review. Modifications to both the Duck Creek
and Stephen’s Creek facilities should be made to reduce
stress and injury to captive bison. An independently reviewed
and enforceable protocol for the humane treatment of bison should
be developed and implemented if quarantined bison will be processed
through the Stephen’s Creek and Duck Creek facilities.
The Duck Creek facility should be openly accessible to the media
and independent observers to ensure humane standards of handling.
Hazing practices should be independently reviewed and modified
to reduce stress on captured bison.

DOMESTICATION OF QUARANTINED BISON
The current protocol for quarantining captured bison from YNP
targets only seronegative long calves. These bison will be between
the ages of nine months and one year of age when they are captured.
Some of them, especially those whose mothers are not pregnant
may still be nursing when captured. Bison typically stay with
their family group until at least two years of age. Female bison
will remain with their family groups indefinitely. Young bison
gain a wealth of experience from their elders. The dynamics
of the herd are learned and established primarily in the second
and third years as bison mature in the presence of the rest
of herd. Younger bulls learn mating rituals through competition
with older bulls and patterns are established that may continue
throughout the life of a particular buffalo to the benefit of
the rest of the herd through natural selection. Bison in Yellowstone
National Park, while certainly familiar with humans, are not
typically handled by humans and demonstrate a level of wildness
that is unknown in comparison to other genetically pure bison.
It has taken the bison in Yellowstone many years to recover
their wild character compromised by previous handling and captivity
before 1967. Some bison, particularly those in the Pelican Valley,
have never been handled by humans, giving Yellowstone bison
their unique position among all other herds.

Captured and quarantined calves will not have developed into
their full nature as wild animals before their captivity. Breeding
in the wild is an integral part of the natural behavioral patterns
developed by bison over tens of thousands of years. Past activity
that has compromised this wild nature should not be used as
an example for the development of programs that further erode
the wildness of the bison. It has taken a long time for the
bison in YNP to recover from the invasive human activities of
the past. Many of the past activities when viewed with hindsight
were clearly misguided. The only reason that brucellosis exists
in GYA wildlife is due to the forced captivity of bison in the
Park and poor decisions of managers. The addition of bison to
YNP at the turn of the twentieth century is hardly something
that should be looked at with pride. A hands off approach at
that time would have eventually led to a disease free herd of
truly wild and pure bison that exhibited the particularly unique
genetic characteristics that bison in the GYA had before human
intervention. If lessons are to be leaned from the past, they
should be that of caution and the exercise of restraint in intervening
in the natural patterns of wild animals.

The bison that will “graduate” from the quarantine
feasibility study cannot be considered “wild” animals
upon their release. It will take generations before they will
exhibit any resemblance to the wild bison of YNP. In fact, they
may never truly redevelop a wild character without exposure
to bison that have not been through the protocol. There is an
ancient wisdom to the bison in YNP because of their connection
to the wild days of old. These intensively handled, relocated
bison will lose this natural connection and their sense of place
in unfamiliar surroundings.
IMPACTS ON THE POPULATION DYNAMICS OF THE YELLOWSTONE HERD
Current operation of the IBMP includes the testing and release
of seronegative bison in addition to the slaughter of seropositives.
The removal of seronegative calves from the population for quarantine
along with the slaughter of seropositive calves is resulting
in the removal of an entire age class from the subpopulation
of bison that are migrating outside Park borders. If capture
activities intensify over the coming months, it is entirely
possible that long calves will be removed from a subpopulation
of nearly 500 bison. The elimination of this age class will
have negative impacts on the dynamics of the affected subpopulation.
Analysis of this impact on the specifically affected subpopulation
should be analyzed before this activity continues and intensifies.
The slaughter of all captured buffalo based on the target population
of 3000 bison should not be used as a justification or a reason
to exclude this analysis from the discussion. The fact is that
current operations do allow for the release of seronegative
bison and therefore the impacts of removing long calves from
the population should be analyzed.

IMPACTS ON FUTURE MANAGEMENT OPTIONS WITHIN THE GYA
The addition of quarantine to the current management scheme
under the IBMP may have significant impacts on the possibility
of adapting the Plan to accommodate a larger population of bison
that can roam freely in an expanded range within the GYA. Acquisition
of additional habitat in the northern and western boundary areas,
the removal of grazing leases on public lands, the incorporation
of new science on the transmissibility of brucellosis between
bison and cattle, a recalculation of the target population,
and the redefinition of the necessary size and period of spatial
and temporal separation are all factors that may lead to greater
tolerance of untested bison in the GYA. If the IBMP ever advances
to stage three, there will be a level of untested bison tolerated
in the northern and western boundary areas. The achievement
of a “successful” quarantine protocol may lead to
the desire for capture operations that would otherwise not be
conducted in stage three. If there is a desire to provide bison
for quarantine, then it will be necessary to continue capturing,
testing and slaughtering bison that may otherwise roam freely.

APHIS NEPA COMPLIANCE
The categorical exclusion claimed by APHIS to avoid NEPA analysis
of the quarantine feasibility study is not consistent with the
intent of the National Environmental Policy Act. The proposed
study is not simply a research project with no long-term impacts.
If all of the bison were slaughtered and cultured and the project
was discrete, then the research exemption might apply. However,
some bison presumably will be relocated outside the GYA at the
end of the protocol. Therefore, for all intents and purposes,
the proposed study is the beginning of quarantining and relocating
bison from YNP and should be reviewed in its entirety, including
the long-term impacts on the human environment of relocating
bison from YNP. Additionally, Montana Fish, Wildlife and Parks
should expand the current analysis to look at the entirety of
the proposal and conduct an Environmental Impact Statement on
all aspects of quarantine.

COST/BENEFIT ANALYSIS
A comprehensive cost/benefit analysis of the quarantine proposal
as compared to other means by which the range of YNP bison might
be expanded and population pressures reduced should be conducted
by FWP as part of this process. Due to the detailed formulation
of costs associated with the quarantine protocol and the efforts
made by FWP to acquire land specifically to accommodate phase
three, an analysis of habitat acquisition within the GYA that
may expand the current range of bison migrating into Montana
should be conducted. An analysis of the benefits in establishing
populations of “non-wild” bison on ranges outside
the GYA should be analyzed in relation to the benefits of protecting
and expanding the range of wild bison within GYA.CONCLUSION
I encourage FWP to consider the above factors in creating a
NEPA compliant document relative to the addition of phases two
and three to the quarantine feasibility study. There are significant
impacts to the environment that should be analyzed in relation
to the overall scope of the project. Additional information
should be provided by FWP in order for the public to adequately
analyze the impacts of quarantine. FWP should create a NEPA
document that is inclusive of the entire quarantine protocol
including the future impacts on the remaining bison in the GYA
if the protocol is “successful” and implemented
on a larger level. The analysis should include a discussion
of how quarantine will impact the possibilities of other adaptations
to the IBMP that may provide for more tolerance and an expanded
range for untested bison within the GYA. A cost/benefit analysis
of the project at this stage should be conducted based on the
overall cost in relation to alternative means to accomplish
some of the same goals outlined in the proposal. FWP should
encourage APHIS to fully participate in the NEPA process openly
and with regard to the overall impacts of the proposal.

Thank you for your consideration of the above concerns with
relation to the continuation of the quarantine feasibility study.
Please accept these comments for the record and keep me informed
on all decisions and documents relevant to bison quarantine.